Privacy Policy


BACKGROUND

Beeline provides services procurement and payment automation solutions for companies around the globe. As part of its process management services, Beeline obtains and processes Personal Data on behalf of our customers. In addition, Beeline obtains Personal Data of individuals who register for a Beeline event or webinar, create a profile in a Beeline application, or visit a Beeline website or otherwise submit their information to Beeline. This Privacy Policy describes Beeline’s commitment to privacy and the procedures and policies to protect the Personal Data in Beeline’s possession.

Under this Privacy Policy and the embodied procedures and policies, Beeline complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Beeline has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

This Privacy Policy will be published prominently on Beeline’s website as well as via certain communications with Data Subjects (such as upon login to the Beeline software applications or via e-mails to Data Subjects). This policy may change from time to time, in which case appropriate notifications will be provided. This Privacy Policy was last changed effective May 25, 2018.

With respect to Personal Data of which Beeline is the Data Controller as described herein, you are consenting to the use of your Personal Data by opting-in to Beeline offerings or by continuing to use our offerings or accept our communications without opting-out.

DEFINITIONS & ROLES

Personal Data refers to any information that is identifiable to specific individuals or by which specific individuals can be identified, such as name, identification numbers, email address, mailing address, phone numbers, or other personal characteristics or attributes. Personal Data does not include anonymized information that is not identifiable to a specific individual. Data Subject refers to the individual to whom the Personal Data refers.

Data Controller refers to the owner of the Personal Data that determines the purposes and means of its processing, which in most cases (including when Personal Data is entered into the customer’s instance of the VMS or customer’s Self-Sourcing Solution Private Talent Pool) is the customer of Beeline. There are certain limited circumstances where Beeline’s customer may not be the Data Controller of Personal Data provided to Beeline. This includes when Personal Data is submitted to Beeline’s Self-Sourcing Solution Public Talent Pool, in which case the third party talent provider submitting such Personal Data is the Data Controller. Beeline acts as Data Controller only in the following limited circumstances where it determines the means and processing of the Personal Data: when Beeline collects personal data for marketing purposes, and when a Data Subject signs up as Talent for the Beeline-To-Work Public Talent Pool in connection with Beeline’s Self-Sourcing Solution.

Customer Confidential Information refers to non-public information that is proprietary to our customers and when the Beeline customer is the Data Controller.

Processor refers to the entity that processes Personal Data on behalf of a Data Controller. When the Data Controller is a Beeline customer using Customer Confidential Information or is a third party talent provider using Beeline’s Self-Sourcing Solution Public Talent Pool, Beeline performs the role of Processor.

 

PRIVACY PRINCIPLES

Beeline is committed to individual privacy and recognizes its responsibility for protecting the Personal Data in its possession and care. The Beeline Privacy Policy is embodied in the following principles:

Notice: The Data Controller has the responsibility to ensure that Data Subjects are notified at the time of data collection what Personal Data is collected, how it will be used, and to whom it will be disclosed. For purposes where Beeline is the Data Controller, this Privacy Policy provides this information.

Access: Data Subjects will be granted access to the Personal Data related to them as directed by the Data Controller and will be able to submit corrections to the information where the Data Subject believes it to be inaccurate (see “Inquiries” below). Corrections will be subject to verification and acceptance by the Data Controller.

Data Integrity and Purpose Limitation: Beeline will use Personal Data for the purposes described herein. In the event that a complaint is received, Beeline will take steps to ensure that the Personal Data is accurate and current or will refer you to the Data Controller as appropriate.

Onward Transfer and Choice: With respect to Customer Confidential Information where Beeline is the Data Processor, Beeline will not transfer Personal Data to third parties, other than the Data Controller or their designees and third parties who perform certain services for Beeline. All such parties agree to maintain appropriate procedures to safeguard the Personal Data and use it only for the purposes of providing services. With respect to Beeline’s Self-Sourcing Solution Public Talent Pool where Beeline is the Data Processor, Beeline will transfer Personal Data to third parties (which may include Beeline’s Self-Sourcing Solution customers and their designees) as necessary to provide the services to our customers.

Where Beeline is the Data Controller, Beeline agrees to maintain appropriate procedures to safeguard the Personal Data and use it only for the purposes described herein. If Beeline shares Personal Data with a third-party service provider that processes the data solely on Beeline’s behalf and under Beeline’s instructions, then Beeline will be liable for that third party’s processing of Personal Data in violation of the Principles, unless Beeline can prove that we are not responsible for the event giving rise to the damage.

In the event that Beeline receives a lawful request to disclose personal information by public authorities, including to meet national security or law enforcement needs, Beeline will comply with the request.

Security: Beeline will treat all Personal Data as confidential and will maintain internal procedures and security safeguards designed to prevent inappropriate disclosure or misuse of Personal Data by Beeline staff.  Beeline personnel are responsible for protecting Personal Data and Customer Confidential information, are trained in the applicable policies, and are expected to adhere to the procedures and intent of this Privacy Policy.

Enforcement: Data Subjects who believe that their Personal Data was not handled in accordance with this Privacy Policy should contact Beeline’s Privacy Officer (see “Inquiries” below), who will conduct an investigation and report their findings to the Data Subject. European Union (EU) or Switzerland residents may also make use of the appropriate Data Protection Authorities; Beeline will cooperate with EU or Swiss Data Protection Authorities to investigate and resolve complaints, including complying with any resulting advice given by the Data Protection Authorities.

 

POLICY PRACTICES

Information Processed

In its role as Data Processor, Beeline receives and processes Personal Data and Customer Confidential information from several sources in the normal course of business, including Identification and contact information from customers, customers’ services suppliers, third party talent providers, and the Data Subjects themselves; and Business process information (such as regarding services procurement and payment processes) through the usage of the Beeline applications and communications among customer users and their services suppliers, the Data Subjects, Beeline users, and third-party users.

As Data Controller, Beeline processes transaction and information system usage information from Beeline applications and Beeline websites. Beeline also collects information from other contacts you have with Beeline (including communications and other information you provide to us) and from third parties. This may include information obtained from cookies, which Beeline uses for a variety of reasons including remembering registration information, to track whether or not you have already participated in a given survey, and to autopopulate correspondence details). Beeline also processes personal data for marketing purposes, which may include contact information (name, email address, phone numbers), geographic information (state, country), billing information (billing address, payment card information), job data (title, company information, industry), emergency contact information, and other optional information you may provide (such as meal preferences, biographies, websites, social media accounts, and photographs).

Why This Information Is Collected

Beeline processes Customer Confidential Information for the purpose of providing our services to our customers, including tasks as directed or authorized by the Data Controller and in order to improve and design our service offerings.

Beeline processes Personal Data received from third party talent providers or from Data Subjects directly via the Self-Sourcing Solution for the purpose of facilitating procurement of Self-Sourcing Talent by Beeline customers.

As Data Controller, Beeline may directly collect Personal Data from you for contact or marketing purposes when you consent to such use in connection with registering for a Beeline event or webinar, creating a profile in a Beeline application, visiting a Beeline website, or otherwise submitting Personal Data to Beeline. Beeline may also receive personal data about you from publicly available sources and third parties (including partners, analysts, social media, and hosts of events, conferences, and webinars) and may use such data for its legitimate interest of marketing purposes and based on your consent to such processing. Such personal data may be stored for such period of time until no longer required by Beeline to fulfill its purpose or until you request to have your personal data erased.

How This Information Is Used

Beeline uses Personal Data only for the purposes for which it was collected as described above. In addition, where Beeline acts as Data Processor, Beeline will perform legitimate and relevant tasks as directed or authorized by the Data Controller.

In the normal course of business, Personal Data and Customer Confidential information is processed by Beeline and via third parties who are contracted to provide certain services to Beeline or our customers. Personal Data submitted in connection with Beeline’s Self-Sourcing Solution may be provided to third parties including Beeline’s customers or their designees. Personal Data may also be transferred to third parties of the Data Controller and their authorized agents in the course of performing the process management services.

With respect to marketing information of which Beeline is the Data Controller, recipients of your Personal Data include Beeline and its affiliates (which may be located in the European Union, Australia, or the United States) as well as sponsors of webinars or events for which you register and third parties engaged to perform services for Beeline, such as marketing research and automation (which may be located in and involve data transfers to such countries without an adequacy decision pursuant to the Standard Contractual Clauses or based on your consent).

 

INFORMATION SECURITY

Personal Data in Beeline’s possession is protected by its Information Systems Security Policy, which is designed to prevent unauthorized disclosure, misuse, or alteration of Personal Data. The Information Systems Security Policy includes confidentiality procedures applicable to all Beeline personnel, security requirements for physical and electronic security, and compliance policies and procedures for information handling. All Beeline personnel are required to acknowledge understanding of the Information Systems Security Policy, and adherence is enforced.

 

INQUIRIES

To inquire about any aspect of this Privacy Policy, Personal Data held, or uses of the Personal Data, please contact the Beeline Privacy Officer via email at privacy@beeline.com, via telephone at +1-303-563-1500, or via mail to Beeline at 6465 Greenwood Plaza Boulevard, Suite 800, Centennial Colorado 80111 USA. Data Subjects in the European Union may also contact Beeline’s Local Representative (Beeline.com, Ltd.) via email at LocalRepresentative@beeline.com or by mail to Beeline at Kean House, 6 Kean Street, London, WC2B 4AS.

For inquiries from Data Subjects about their Personal Data, Data Subjects should contact the Data Controller. Where a Data Subject instead submits an inquiry to Beeline and Beeline is not the Data Controller, Beeline will forward the inquiries to the appropriate Data Controller and assist with resolving the inquiry, including providing access to the Personal Data and correcting any errors in cooperation with the Data Controller.

Where Beeline is the Data Controller and to the extent the EU General Data Protection Regulation applies to you: (i) you may request from Beeline access to, rectification, erasure, or restriction of processing concerning your personal data; (ii) you have the right to object to the processing, the right to data portability, and the right to lodge a complaint with a supervisory authority; and (iii) you may contact Beeline regarding the source of any third party which provided your personal data to Beeline. With respect to such marketing data, you may withdraw your consent at any time by unsubscribing, updating your email preferences, or contacting Beeline to request erasure of your personal data. In the event you withdraw your consent or decline to provide any required personal data, you will not be able to receive future communications, register for events/webinars, download website content, or participate in the Beeline Community or other services offered by Beeline (including Beeline’s Self-Sourcing Solution).

ALTERNATIVE DISPUTE RESOLUTION (ADR)

In compliance with the Privacy Shield Principles, Beeline commits to resolve complaints about our collection or use of your Personal Data.  Individuals with inquiries regarding our Privacy Shield policy or complaints regarding the handling of your personal information should contact privacy@beeline.com.

Beeline has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please email privacy@beeline.com for more information.  The services of JAMS are provided at no cost to you. To learn more about JAMS, click here. To learn more about binding arbitration under the EU-U.S. Privacy Shield regulation, click here.

 

COOKIE POLICY

What Are Cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

Cookies We Set

This website does not set any cookies unless the user is logged in. These cookies do not contain any user information and use a unique numeric value to verify the user’s login status and specific roles or permissions associated with the user.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • Pardot.com

This website offers marketing and sales information about our products, and cookies may be for page performance and user viewing trends.  No personal information is stored or needed to provide Pardot.com with this information.

  • Google.com

This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

For more information on Google Analytics cookies, see the official Google Analytics page.

 

More Information

If you are still looking for more information you can contact us through one of our preferred contact methods.

Email: privacy@beeline.com

Further Information

If you want to know more about our commitment to Privacy, please contact us at privacy@beeline.com.

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